ORAU TEAM

Dose Reconstruction

Project for NIOSH

Oak Ridge Associated Universities I Dade Moeller & Associates I MJW Corporation

Page 1 of 5

Document Title:

Pacific Northwest National Laboratory –

Occupational Internal Dose

Document Number: ORAUT-TKBS-0027-5

Revision: 01

Effective Date: 05/18/2007

Type of Document: TBD

Supersedes: Revision 00

Subject Expert(s): Edward D. Scalsky

Site Expert(s): Donald E. Bihl

Approval: Signature on File Approval Date: 05/03/2007

Edward D. Scalsky, Document Owner

Concurrence: Signature on File Concurrence Date: 05/04/2007

John M. Byrne, Task 3 Manager

Concurrence: Signature on File Concurrence Date: 05/03/2007

Edward F. Maher, Task 5 Manager

Concurrence: James P. Griffin Signature on File for Concurrence Date: 05/03/2007

Kate Kimpan, Project Director

Approval: Brant A. Ulsh Signature on File for Approval Date: 05/18/2007

James W. Neton, Associate Director for Science

 New Total Rewrite Revision Page Change

DOCUMENTS MARKED AS A TOTAL REWRITE, REVISION, OR PAGE CHANGE REPLACE THE PRIOR REVISION. 

PLEASE DISCARD / DESTROY ALL COPIES OF THE PRIOR REVISION.
Document No. ORAUT-TKBS-0027-5 Revision No. 01 Effective Date: 05/18/2007 Page 2 of 5

PUBLICATION RECORD

EFFECTIVE 

DATE

REVISION 

NUMBER DESCRIPTION

08/12/2005 00 New technical basis document for the Pacific Northwest National 

Laboratory occupational internal dose. First approved issue. 

Initiated by Edward D. Scalsky. 

05/18/2007 01 Approved revision initiated to include Attribution and Annotation

section. Constitutes a total rewrite of the document. No further 

changes occurred as a result of formal internal review. This revision 

results in no change to the assigned dose and no PER is required. 

Training required: As determined by the Task Manager. Initiated by 

Edward D. Scalsky.
Document No. ORAUT-TKBS-0027-5 Revision No. 01 Effective Date: 05/18/2007 Page 3 of 5

TABLE OF CONTENTS

SECTION TITLE PAGE

 5.1 Introduction.................................................................................................................................4

5.2 Attributions and Annotations .......................................................................................................5

References ..........................................................................................................................................5
Document No. ORAUT-TKBS-0027-5 Revision No. 01 Effective Date: 05/18/2007 Page 4 of 5

5.1 INTRODUCTION

Technical basis documents and site profile documents are not official determinations made by the 

National Institute for Occupational Safety and Health (NIOSH) but are rather general working 

documents that provide historic background information and guidance to assist in the preparation of 

dose reconstructions at particular sites or categories of sites. They will be revised in the event 

additional relevant information is obtained about the affected site(s). These documents may be used 

to assist NIOSH staff in the completion of the individual work required for each dose reconstruction.

In this document the word “facility” is used as a general term for an area, building, or group of

buildings that served a specific purpose at a site. It does not necessarily connote an “atomic weapons 

employer facility” or a “Department of Energy [DOE] facility” as defined in the Energy Employees 

Occupational Illness Compensation Program Act [EEOICPA; 42 U.S.C. § 7384l(5) and (12)]. 

EEOICPA defines a DOE facility as “any building, structure, or premise, including the grounds upon 

which such building, structure, or premise is located ... in which operations are, or have been, 

conducted by, or on behalf of, the Department of Energy (except for buildings, structures, premises, 

grounds, or operations ... pertaining to the Naval Nuclear Propulsion Program)” [42 U.S.C. § 

7384l(12)]. Accordingly, except for the exclusion for the Naval Nuclear Propulsion Program noted 

above, any facility that performs or performed DOE operations of any nature whatsoever is a DOE 

facility encompassed by EEOICPA.

For employees of DOE or its contractors with cancer, the DOE facility definition only determines 

eligibility for a dose reconstruction, which is a prerequisite to a compensation decision (except for 

members of the Special Exposure Cohort). The compensation decision for cancer claimants is based 

on a section of the statute entitled “Exposure in the Performance of Duty.” That provision [42 U.S.C. § 

7384n(b)] says that an individual with cancer “shall be determined to have sustained that cancer in the 

performance of duty for purposes of the compensation program if, and only if, the cancer ... was at 

least as likely as not related to employment at the facility [where the employee worked], as 

determined in accordance with the [probability of causation1

As noted above, the statute includes a definition of a DOE facility that excludes “buildings, structures, 

premises, grounds, or operations covered by Executive Order No. 12344, dated February 1, 1982 (42

U.S.C. 7158 note), pertaining to the Naval Nuclear Propulsion Program” [42 U.S.C. § 7384l(12)].

While this definition contains an exclusion with respect to the Naval Nuclear Propulsion Program, the 

section of EEOICPA that deals with the compensation decision for covered employees with cancer 

[i.e., 42 U.S.C. § 7384n(b), entitled “Exposure in the Performance of Duty”] does not contain such an 

exclusion. Therefore, the statute requires NIOSH to include all occupationally derived radiation 

exposures at covered facilities in its dose reconstructions for employees at DOE facilities, including 

radiation exposures related to the Naval Nuclear Propulsion Program. As a result, all internal and 

external dosimetry monitoring results are considered valid for use in dose reconstruction. No efforts 

are made to determine the eligibility of any fraction of total measured exposure for inclusion in dose 

reconstruction. NIOSH, however, does not consider the following exposures to be occupationally 

derived:

] guidelines established under subsection 

(c) ...” [42 U.S.C. § 7384n(b)]. Neither the statute nor the probability of causation guidelines (nor the 

dose reconstruction regulation) define “performance of duty” for DOE employees with a covered 

cancer or restrict the “duty” to nuclear weapons work.

• Radiation from naturally occurring radon present in conventional structures

 1 The U.S. Department of Labor is ultimately responsible under the EEOICPA for determining the 

probability of causation (POC).
Document No. ORAUT-TKBS-0027-5 Revision No. 01 Effective Date: 05/18/2007 Page 5 of 5

• Radiation from diagnostic X-rays received in the treatment of work-related injuries

The Internal Dosimetry program at the Pacific Northwest National Laboratory (PNNL) is the same 

program that existed at Hanford subsequent to01/03/1965 when Battelle Memorial Institute (BMI) 

assumed responsibility for operation of the Hanford Laboratories and certain Hanford-wide services 

and functions as part of the Atomic Energy Commission (AEC) operations at the Hanford site. Since 

that is the case, it has been determined that any dose reconstructions that incorporate the dose 

received by PNNL employees as a result of internal exposure will be determined based on the 

programs described in the corresponding Hanford TBD, Technical Basis Document for the Hanford 

Site – Occupational Internal Dose (ORAUT 2004a), and its Attachment D (ORAUT 2004b).

5.2 ATTRIBUTIONS AND ANNOTATIONS

Donald Bihl served as the initial Subject Expert for this document. Mr. Bihl was previously employed 

at PNNL and his work involved management, direction or implementation of radiation protection 

and/or health physics program policies, procedures or practices related to atomic weapons activities 

at the site. This revision (and original revision) has been overseen by a Document Owner who is fully 

responsible for the content, including all findings and conclusions. Mr. Bihl continues to serve as a 

Site Expert for this document because he possesses or is aware of information relevant for 

reconstructing radiation doses experienced by claimants who worked at the site. In all cases where 

such information or prior studies or writings are included or relied upon by Mr. Bihl, those materials 

are fully attributed to the source. Mr. Bihl’s Disclosure Statement is available at www.oraucoc.org.

All information requiring identification was addressed in ORAUT (2004a, 2004b).

REFERENCES

ORAUT (Oak Ridge Associated Universities Team), 2004a, Technical Basis Document for the 

Hanford Site – Occupational Internal Dose, ORAUT-TKBS-0006-5, Rev. 01, Oak Ridge, 

Tennessee, November 24.

ORAUT (Oak Ridge Associated Universities Team), 2004b, Technical Basis Document for the 

Hanford Site – Attachment D Occupational Internal Dose, ORAUT-TKBS-0006-5, Rev. 01, 

Oak Ridge, Tennessee, November 24.